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In re A.H.
No. 89418 (Ill. Sup. Ct. Apr. 19, 2001) ; Clearinghouse Number: 53810
Description
Illinois Supreme Court Finds That Juvenile Court Properly Applied “Best Interest” Standard to Order Removal of Child from Foster Care Placement
Abstract
The Illinois Supreme Court held that the juvenile court needed only
to engage in the “best interest” determination, as the
Juvenile Court Act outlined it in section 1-3(4.5), when the
juvenile court entered an order related to the temporary custody of
a minor. At a pretrial hearing guardian ad litem made an oral
emergency motion, alleging physical abuse, for the removal of a
child from his foster home. Department of Children and Family
Services asserted that the juvenile court lacked the authority to
sidestep its administrative appeal process. In response, guardian
ad litem argued that the language of section 2-10(2) of the Act
granted the juvenile court broad authority to select a
child’s placement. The juvenile court applied the standards
that section 2-10 of the Act set forth for a temporary custody
hearing; it found probable cause to believe the child was abused or
neglected and urgent necessity to support the removal from the
foster home; it noted that reasonable efforts could not prevent or
eliminate the necessity of that removal. The juvenile court also
concluded that removal from the foster home was consistent with the
child’s health, safety, and best interest. Agreeing with the
juvenile court, the state supreme court explained that section 2-10
of the Act authorized the juvenile court to enter such other orders
related to the temporary custody of minors as it deemed fit and
proper, including orders to remove minors from temporary foster
care. The supreme court said that the juvenile court must make a
“best interest” determination, which did not require
considerations of urgent necessity or reasonable efforts.
